JUDGMENT

JASWANT SINGH, J. :—These appeals by special leave from the common judgment of the Mardars High Court dated March, 5, 1974, in Tax Cas Cases Nos. 77 and 78 of 1974 which involve the interpretation of Section 3 and item No. 21 of the First Schedule to the Tamil Nadu General Sales Tax Act, 1959 hereinafter referred to as the Act , shall be disposed of by this judgment.

2. The appellant, Tvl. Shaw Wallace & Co. Ltd., a public limited company, is a registered dealer under the Act and is an assessee on the rolls of the Commercial Tax Officer IV, Central Assessment Circle-23, Madras Amongst other things, the appellant manufactures, and deals in chemical fertilisers. It also prepares fertilisers mixtures. For the assessment years 1969-70 and 1970-71, the appellant claimed exemption on a turnover of Rs. 2,35,01,129.47 and Rs. 2,07,94,490.73 respectively relating to sales of fertiliser mixtures. The case of the appellant was that as the fertiliser mixtures were prepared by dry mixing of various chemical fertilisers (shown as sub-items (1) to (15) of S. No. 21 of First Schedule to the Act) according to the standard formula approved by the Director of Agriculture at its mixing works